Expert Analysis

E-invoicing is currently characterised by dynamism, with fragmentation acting as a key catalyst for increasing interoperability, says Aida Cavalera of the International Observatory on eInvoicing

A recent decision underlines that Indian courts are more willing to look beyond just legal compliance and examine whether foreign investment structures have real business substance

Countries that care about the fair taxation of tech multinationals and equitable global distribution of wealth should back the UN’s tax framework, writes economist Abdelmalek Riad

Sudin Sabnis and Siddhesh Khandalkar of Lakshmikumaran and Sridharan explore how context shapes the interpretation of undefined terms in tax treaties, balancing treaty text, domestic law, and diplomatic intent

Fumiko Mizoguchi, partner, Tax & Legal, Deloitte Japan

Uday Ved, Hetav Vasani, and Snehal Pawar of KNAV India explore how cross-border business restructuring can trigger hidden tax exposures such as exit charges, and examine valuations under evolving global transfer pricing rules

Stephanie Eichenberger and Thomas Zellweger of Tax Partner explain how the choice of investment vehicle impacts the eligibility of non-Swiss investors for Swiss withholding tax refunds and, ultimately, investment performance

Ricardo Villalobos of Copper Wolf examines how BEPS pillars one and two reshape global tax rules, potentially affecting domestic systems and closing gaps in multinational corporate tax avoidance

Mikael Jacobsen and Henri Ahtiainen of Skeppsbron Skatt explore how several recent Swedish cases have shed light on the complex distinction between legal and economic ownership of intellectual property in transfer pricing matters

Gabriel Caldiron Rezende and Rafaela Calçada Cruz of Machado Associados discuss the impacts of the consumption tax reform on agribusiness, focusing on sector-specific concessions, challenges, and strategic responses

João Riscado Rapoula and André Vilaça Ferreira of VdA outline the NHR 2.0 Portuguese tax incentive and explain why it could enhance the country’s appeal to expatriates and foreign businesses

Jun Au of DLA Piper Australia analyses a recent Full Federal Court decision on the Australian Taxation Office’s application of the general anti-avoidance rules, with the judgment also addressing dividend stripping and the taxation of financial arrangements